Privacy Notice

1 Privacy Notice for Clean Sheet

 

1.1 Definitions

  • Personal Data – any information relating to an identified or identifiable natural person.
  • Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
  • Data subject – a natural person whose Personal Data is being Processed.
  • Child – a natural person under 16 years of age.
  • We/us (either capitalized or not) – Clean Sheet

2 Introduction

Clean Sheet (“We”) respect your privacy and are determined to protect your personal data. The purpose of this privacy notice is to inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from). We’ll also tell you about your privacy rights and how the data protection law protects you.

Clean Sheet is the controller and responsible for your personal data (collectively referred to as “we”, “us” or “our” in this privacy notice – capitalised or not). Clean Sheet is a Charitable Incorporated Organisation, number 1154034. Our Site is owned and operated by us and our registered address is:

c/o Caladine
Chantry House
22 Upperton Road
Eastbourne
BN21 1BF

The Trustees and Management of Clean Sheet are the data controllers responsible for general data protection matters and complaints concerning day-to-day matters. We have appointed a Data Protection Lead responsible for overseeing questions concerning this privacy notice. Queries related to Data Protection should be directed to the Data Protection Lead (see the section “How to Contact Us”).

2.1 Purpose Of This Privacy Notice
This privacy notice aims to give you information on how Clean Sheet collects and processes your personal data which either you have provided to us or we obtain. This notice applies to the personal information we collect about you directly or that we collect from third parties.
It sets out:

  • what personal data we collect;
  • how we use your data;
  • lawful basis;
  • how long we keep your information;
  • how your information is protected;
  • who we share your information with;
  • international transfers;
  • your rights in relation to the information we hold about you;

This website is not intended for children, and we do not knowingly collect data relating to children.

Queries related to Data Protection should be directed to the Data Protection Lead (see the section “How to Contact Us”)

2.2 Third-party links outside our control
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

3 The Personal Data We Collect

Personal data, or personal information, means any information about an individual from which that person can be identified. You can find out more about personal data from the Information Commissioner’s Office.

Interactions with Clean Sheet may be made in the following ways (this is not an exhaustive list):

  • Complete the Membership Module (our joining paperwork); joining us as a Member will include us registering you so that you can log into our Employers Directory
  • Request a call back through our website
  • Register for an event with us
  • Donate money to us including Gift Aid status and records of donations
  • Otherwise interact with us or provide information to a third party to be referred to us

We may collect, use, store and transfer different kinds of personal data about you which we have grouped as follows:

  • Identity Data includes first name, surname, username, title, date of birth, gender.
  • Contact Data includes telephone number/s and email address.
  • Financial Data includes bank account number, sort code.
  • Technical Data includes IP address, your login data, browser type and version, location, operating system, and other technology on the devices you use to access this website.
  • Profile Data includes username and password.
  • Usage Data includes information about how you use our website, products and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties, your communication preferences.

Where we request information from you, this will be explained in the relevant forms or pages, or over the telephone. You may choose to provide additional information when you interact with us or to a third party who refers you to us.

Applying to work for us:
We will collect data you give us when applying for a job or volunteering with us. This may include:

  • your bank account details and tax and residency status;
  • references from previous employers or educational institutions;
  • contact details for you, and any next of kin;
  • qualifications;
  • information concerning your health and medical conditions;
  • information about your age, ethnicity and disabilities;
  • details of unspent criminal convictions.

3.1 Special Category Data
Where data processing relates to Special Categories of Data the following processing conditions apply:

  • Explicit Consent has been given by the data subject.
  • Processing is necessary for carrying out obligations under employment, social security or social protection law, or a collective agreement.

3.2 Social Media Users
We use social media channels (including Facebook, WhatsApp, X and YouTube, the “Social Media Companies”) to publish information about the charity. If you follow or otherwise engage with our social media channels, we will collect Usage Data to analyse how users interact with those channels. If you use social media to send us messages or posts, we may use your Profile Data to communicate with you. When you interact with our channels, the
Social Media Companies will also process your personal data for the purposes set out above.

For more information, we would encourage you to review the privacy notices published by the Social Media Companies.

4 How Can You Control Your Data?

When you submit information via our Site, you may be given the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in our emails or by emailing us.

You may access certain areas of our Site without providing any data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

You may withdraw your consent for us to use your personal data at any time by contacting us and we will delete your data from our systems. However, you acknowledge this may limit our ability to provide the best possible products and services to you (see the section on How to Contact Us).

Please tell us as soon as any of your contact details change so that we can keep our records up-to-date.

5 How We Use Your Data

We use your data to provide the best possible products and services to you.

This includes:

  • Providing and managing your access to our Site.
  • Personalising and tailoring your experience on our Site.
  • Supplying our products and services to you.
  • Responding to communications from you.
  • Analysing your use of our Site and gathering feedback to enable us to continually improve our Site and your user experience.

In some cases, the collection of data may be a statutory or contractual requirement, and we will be limited in the products and services we can provide you without your consent for us to be able to use such data.

5.1 Direct Marketing
We may from time to time supply you with email newsletters, alerts etc. These may form part of the service we provide and we do not send unreasonable volumes. (You may unsubscribe or opt-out at any time by clicking the ‘unsubscribe’ link in the email or by contacting us – see the section on How to Contact us).

If you have registered to receive a newsletter from us (not as part of a service provision), we may use your details for marketing purposes which may include contacting you by email, telephone, or text message with information, news and offers on our products and services (once again, you may unsubscribe by using the link in an email or contacting us). We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that we fully protect your rights and comply with our obligations under the DPA 2018, GDPR, and the Privacy and Electronic Communications Regulations 2003.

6 Lawful Basis

Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following bases applies:

  • You have given consent to the processing of your personal data for one or more specific purposes.
  • Processing is necessary for the performance of a contract to which you are a party or to take steps at your request of you prior to entering a contract.
  • Processing is necessary for compliance with a legal obligation to which we are subject.
  • Processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data.

We rely on our legitimate interests for the following reasons:

  • keeping our records up to date;
  • developing, marketing and charging for our products and services;
  • running our websites and keeping them safe and secure;
  • presenting our content and communications in the most effective and sustainable manner for you and your devices;
  • helping you use our websites, including obtaining products or services;
  • measuring how you use our websites and improving their content and accessibility;
  • measuring and understanding how effective our adverts are;
  • carrying out campaign work and developing our policy;
  • complying with legal and or regulatory requirements;
  • identifying consumer trends;
  • understanding products, services and the consumer experience;
  • and to provide insight and analysis into how our social media channels are used and how they are performing.

7 How do we Store and How long do We keep your data

Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

Our retention of your personal data is linked to your actions. Unless a longer retention period is required or permitted by law, we will only hold your Personal Information on our systems for the period necessary to fulfil the purposes outlined in this Notice, or until you request that the information be deleted (see the section “Summary of Your rights”).

Please see our Retention Schedule for a detailed list of our retention periods: www.cleansheet.org.uk/data-retention-schedule
Even if we delete your Personal Information, we reserve the right to retain your personal data where such retention is necessary for compliance with a Statutory obligation (for example, to maintain a copy for legal, tax, or regulatory purposes,) but in such an event, we will do so only as long as necessary to fulfil those Statutory obligations.

7.1 Data Security
Data security is of great importance to us, and to protect your data we have put in place suitable physical, electronic and managerial procedures to safeguard and secure data collected through our Site.

All your data is stored electronically in a secure database or in a locked filing cabinet and can only be accessed by authorised people. All users of our system are trained in GDPR. Where we engage third parties to process personal data on our behalf, they do so upon writing and are contracted to implement appropriate technical and organisational measures to ensure the security of data.

8 Who We Share Your Personal Data With

We are committed to not sharing your data and will only do this if it is in your legitimate interest to ensure we provide you with the support and information required to make an informed decision about a service(s) or product(s).

We will not sell your data to any unconnected third parties.

We may contract with third parties to supply products and services to you on our behalf. These may include payment processing and search engine facilities. We might share your information across different parts of our organisation for research and analysis.

We may use Artificial Intelligence (AI) platforms to re-write or re-format anonymised text about you. If AI is used in this way, care will be taken that none of your personal data is shared.

We might share your information across different parts of our organisation for research, and analysis.

In some cases, third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

In some cases, third parties may require access to some or all of your data. Where any of your data is required for such a purpose, we will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, our obligations, and the obligations of the third party under the law.

We currently contract with:

Third party
name		 Used to Privacy notice
Mailchimp Marketing emails https://www.intuit.com/privacy/statement/
Truebyte ICT Services https://www.truebyte.co.uk/resources/pdf/True
bytePrivacyNotice.pdf
Etapestry CRM https://www.blackbaud.co.uk/company/privacypolicy/europe
MS365 Documentation
creation and storage		 https://privacy.microsoft.com/engb/privacystatement
YouManage  HR https://www.youmanage.co.uk/privacy-policy/
QuickBooks Finance https://www.intuit.com/privacy/statement/
PayPal Ordering Goods https://www.paypal.com/myaccount/privacy/privacyhub
Equals Money Ordering Goods https://equalsmoney.com/privacy
Wonderful Online Donations https://wonderful.support/downloads/wp_privacy_policy_v2.3_oct_2023.pdf
CAF Online Donations https://www.cafonline.org/privacy
Cintra Staff Payroll
Processing/HMRC
liaison		 https://cintra.co.uk/privacy-notice/
Legal & General Staff Pensions https://www.legalandgeneral.com/privacy-notice/
HMRC Staff tax, NI, sickness
pay, maternity,
paternity, adoption
pay and leave, social
security information		 https://www.gov.uk/government/publications/dataprotection-act-dpa-information-hm-revenue-andcustoms-hold-about-you
Disclosure and
barring service		 Staff recruitment
checks		 https://www.gov.uk/government/publications/basicdbs-check-privacy-policy

We may have to share your personal data with the parties set out below for the purposes set out in the table above.

  • External Third Parties Service
  • Recruitment agencies who may hold details of any CV or personal data you have given them
  • Providers based in the UK who provide IT and system administration services.
  • Professional advisers including lawyers, bankers, auditors and insurers based in the UK who provide consultancy, banking, legal, insurance and accounting services.
  • HM Revenue & Customs, regulators and other authorities based in the UK who require reporting of processing activities in certain circumstances.
  • Third parties to whom we may choose to sell, transfer, or merge parts of our charity or our assets. Alternatively, we may seek to acquire other charities or merge with them. If a change happens to our charity, then the new owners may use your personal data in the same way as set out in this privacy notice.
  • We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

8.1 International Transfers
We may need to transfer some personal data to the third parties described above who are located outside the UK. In such cases, we will take appropriate measures to ensure your personal data remains protected. If the organisation is based outside the UK and in a country that is not protected by an adequacy decision (providing an adequate level of data protection) we will take appropriate safeguards such as implementing the ICO’s International Data Transfer Agreement (IDTA).

If you have any questions or need more information regarding international transfers of your personal data, please contact us (see the section on How to Contact Us).

8.2 Automatic Collection, Cookies and Aggregate Information collected from our Website
We automatically collect some data from visitors to our websites. This includes what pages you have viewed, for how long and where you go on our website.

We use cookies to store information about how you use our sites. A cookie is a piece of data stored on a user’s computer to remember information about you and create a profile of your viewing preferences. Your profile is used to tailor your visit to our website, make navigation easier, and direct you to information that best corresponds to your interests. We require your consent to place non-essential cookies on your device. You can change your cookie preferences by selecting the button in the bottom left corner from any page on our website. View our cookies policy https://www.cleansheet.org.uk/cookie-policy/

Aggregate information is collected from users using our own web tracker. This information includes users’ Anonymised Internet Protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time of visit, number of clicks, error pages, and number of unique visits. This information is not linked to personal profiles or personally identifiable information provided by users. We use the information to analyse visitor trends and use of our website, administer the website, and gather broad demographic information of our website users.

We may use the information we receive and/or collect about you to:

  • Fulfil our obligations under any contract that we have entered into with you or with a Resident that you represent, and to provide you or the relevant Resident with information or services that you or the Resident has requested;
  • Monitor website usage and provide statistics to third parties for the purposes of improving and developing the website and the services we provide via the website.

Summary of Your Rights

As a data subject, you have several rights and control over how your data is used.

  • You can request access to, deletion of, or correction of, your personal data held by us.
  • You can ask for a copy of the data you have given us.
  • You can require us to amend or change incorrect or incomplete data.
  • You can require us to delete or stop processing your data, where the data is no longer necessary for the purposes of processing.
  • You can object to the processing of your data where we are relying on its legitimate interests as the legal ground for processing.
  • You can ask us to stop processing data for a period if data is inaccurate or there is a dispute about whether or not your interests override the charity’s legitimate grounds for processing data.

To enforce any of the foregoing rights or if you have any other questions about our Site or this Privacy Notice, please contact us using the details set out in the section “How to Contact Us”. No fee is required – with some exceptions.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable admin fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally, it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

How to Contact Us

If you have any questions about our Site or this Privacy Notice, please contact us by email at dpl@cleansheet.co.uk or by telephone on 0300 123 3045 and ask for the Data Protection Lead.

Please ensure that your query is clear, particularly if it is a request for information about the data we hold about you.

How to Complain

If you are unhappy with the way that we have processed or handled your data, please contact us (see the section How to Contact Us).

If this does not resolve your complaint to your satisfaction, you have the right to lodge a complaint with the Information Commissioner’s Office (ICO). The ICO is the supervisory body authorised by the Data Protection Act 2018 to regulate the handling of personal data within the United Kingdom. The contact details for the Information Commissioner’s Office are:

  • Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, SK9 5AF
  • Telephone: 0303 123 1113 Website: https://ico.org.uk/concerns/

Changes to Our Privacy Notice

We may change this Privacy Notice as we may deem necessary from time to time, or as may be required by English law. Any changes will be immediately posted on our Site, and you will be deemed to have accepted the terms of the Privacy Notice on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up to date.

[Last updated November 2025]